Clayton M. Korecky, Jr. v. Commissioner of Internal Revenue

In this appeal Clayton M. Korecky, Jr. challenges the decision of the United States Tax Court imposing a fifty-percent civil penalty against him for tax fraud. The Tax Court found that Korecky had understated his tax liability for the years 1972, 1973 and 1974 and that this tax deficiency was the result of fraud. On this appeal, Korecky does not challenge the judgment of tax liability. His sole contention is that the Tax Court erred in finding fraud and imposing the civil penalty. We disagree and affirm the judgment of the Tax Court.

Korecky, a resident of Cocoa, Florida, completed his formal…